We allowing a non-affiliate credit card vendor to conduct a pre-screen (soft hit) on customers that are opening checking accounts for credit card soliciting. We have permissable purpose to allow the pre-screen on individual accounts, but do we have permissable purpose to allow the vendor to complete a pre-screen on signers/owners of a business checking account?
Does permissable purpose cover the pre-screen, or would this only be a violation if we were allowing the vendor to run a hard hit?

Are we allowed to run the pre-screen (soft hit) on these signers/owners if they are under 21? Does the Card Act apply since they are opening a business account?

We do have a joint marketing agreement with the vendor. Terms and Conditions are provided to the customers after they elect to proceed with the initial offer. The Terms and Conditions state that a credit report will be run on the Business and Business owner (employee, officer)for Business Credit Cards.

Prescreen??? - how do you do a prescreen with written permission?? That would constitute an application for credit.

I think you need to get your legal department involved in this process.

Let me state my question differently...

Does permissable purpose apply to pre-screens (soft hits)?

Do we have to have permissable purpose to do a pre-screen on a signer/owner of a business account?

You don't get a prescreen by pulling a soft and hard inquiry. You provide the credit bureau with the specific criteria you use for screening and they tell you whether the customer meets your criteria. You never see an actual credit report.

The point is, unless this is working totally differently than how you have described it, this is not prescreening, so your question about a signer/owner of a business account is moot.